Order

WHEREAS on July 10, 2018, the Mutual Fund Dealers Association of Canada (the “MFDA”) issued a Notice of Settlement Hearing pursuant to section 24.4 of By-law No. 1 in respect of Global Maxfin Investments Inc. (the “Respondent”);

AND WHEREAS the Respondent entered into a settlement agreement with Staff of the MFDA, dated June 14, 2018 (the “Settlement Agreement”), in which the Respondent agreed to a proposed settlement of matters for which the Respondent could be disciplined pursuant to ss. 20 and 24.1 of By-law No. 1;

AND WHEREAS the Hearing Panel is of the opinion that, between December 2011 and January 2015, the Respondent failed to:

1. establish, implement and maintain adequate internal controls to supervise the activities of its Approved Person IC and the client accounts for which IC was the servicing dealing representative so as to:
   1. detect and prevent unusual trading patterns by IC such as excessive trading, excessive switching and market timing;
   2. detect and prevent discretionary trading by IC;
   3. conduct a reasonable supervisory investigation of IC activities after becoming aware that IC maintained and used pre-signed client forms to process transactions in client accounts; and
   4. ensure that the handling of the Respondent’s business was in accordance with the By-laws, Rules and Policies of the MFDA and applicable securities legislation; and
2. maintain adequate records of trade supervision undertaken including inquiries made, responses received and follow-up action taken;

contrary to MFDA Rules, 2.1.4, 2.2.1, 2.3.1, 2.5, 2.9 and 2.10 and MFDA Policy No. 2;

IT IS HEREBY ORDERED THAT the Settlement Agreement is accepted, as a consequence of which:

1. If at any time a non-party to this proceeding, with the exception of the bodies set out in section 23 of MFDA By-law No. 1, requests production of or access to exhibits in this proceeding that contain personal information as defined by the MFDA Privacy Policy, then the MFDA Corporate Secretary shall not provide copies of or access to the requested exhibits to the non-party without first redacting from them any and all personal information, pursuant to Rules 1.8(2) and (5) of the MFDA Rules of Procedure;

2. The Respondent shall pay a fine in the amount of $35,000, pursuant to section 24.1.2(b) of By-law No. 1;

3. The Respondent shall pay the costs of this proceeding and investigation in the amount of $10,000, pursuant to section 24.2 of By-law No. 1; and

4. The Respondent shall in the future comply with MFDA Rules, 2.1.4, 2.2.1, 2.3.1, 2.5, 2.9 and 2.10 and MFDA Policy No. 2.